The subsidy for COBRA coverage under the American Rescue Plan Act comes to an end on September 30, 2021. There is no indication at this time that the subsidy will be extended. That means that, beginning October 1, plan and COBRA administrators may start collecting premium payments from individuals who qualified for COBRA because of a reduction of hours or involuntary termination of employment. More urgently, group health plan sponsors that have not already distributed notice that the subsidy will end must do so on or before September 15.

The government has issued a model Notice of Expiration of Premium Assistance for this purpose. Plan sponsors should confirm that this notice has been issued or take action promptly.